IR 05000361/2014004

IR 05000361/2014004; 05000362/2014004, on 09/30/14, San Onofre Nuclear Generating Station, NRC Inspection Report

ML14321A900
Person / Time
Site:	San Onofre
Issue date:	11/17/2014
From:	Ray Kellar NRC/RGN-IV/DNMS/RSFSB
To:	Thomas J. Palmisano Southern California Edison Co
References
EA-13-083 IR 2014004
Download: ML14321A900 (21)

Text

ber 17, 2014

SUBJECT:

SAN ONOFRE NUCLEAR GEN ER ATING ST A TION-NRC INSPECTION REPORT 050-00361/14-004; 050-00362/14-004

Dear Mr. Palmisano:

This refers to the inspection completed on September 30, 2014, at your permanently shut down San Onofre Nuclear Generating Station facility, Units 2 and 3. The purpose of the inspection was to determine whether decommissioning activities were being conducted safely and in accordance with U.S. Nuclear Regulatory Commission (NRC) requirements.

The enclosed report presents the results of this inspection.

The results of the inspection were discussed with you and other members of your staff on October 8, 2014. During this inspection, NRC staff examined activities conducted under your license as they relate to public health and safety to confirm compliance with the Commission's rules and regulations, and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.

The enclosed report presents the results of this inspection.

The NRC staff completed our review of your actions associated with the White finding and associated Violation by letter dated December 23, 2013(NRC's Agencywide Documents Access and Management System (ADAMS) Accession No. ML13357A058). Th e White finding and associated Violation have been closed. The closure was based on the NRC's conclusion that previously performed Augmented Inspection Team inspections (ML12188A748 and ML12318A342), the Confirmatory Action Letter Response inspection (ML13263A271), and the inspectors'

review of the Organizational and Programmatic Root Cause Analysis have met the objectives of Inspection Procedure 95001, "Supplemental Inspection for One or Two White I nputs in a Strategic Performance Area," to provide assurance that: (1) the root causes and contributing causes of risk-significant performance issues were understood; (2) the extent of condition and extent of cause of issues were identified; and (3) corrective

• actions were sufficient to address the root and contributing causes and prevent recurrence. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter, its enclosure, and your response , if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc

.

rm/adams.html.

To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction. If you have any questions concerning this inspection, please contact Greg Warnick, Senior Resident Inspector, at 949-492-2641.

Sincerely,

/RAJ Ray L. Kellar, P.E., Chief Repository and Spent Fuel Safety Branch Division of Nuclear Materials Safety Docket No.: 50-361 , 50-362 License No: NPF-10, NPF-15

Enclosure:

NRC Inspection Report 050-00361/14-004 and 050-00362/14-004

REGION IV 50-361, 50-362 NPF-10 , NPF-15 050-00361/14-004 and 050-00362/14-004 Southern California Edison San Onofre Nuclear Generating Station, Units 2 and 3 5000 S. Pacific Coast Hwy San Clemente, CA July 1 through September 30, 2014 R. Evans, Ph.D., C.H.P., P.E., Senior Health Physicist G. Warnick, Senior Resident Inspector Ray L. Ke ll ar, P. E., Chief Repository and Spent Fuel Safety Branch Division of Nuclear Materials Safety Supplemental Inspection Information Enclosure EXEC UTI VE SUMMARY Southern California Edison NRC I nspection Report 050-00361/14-004; 050-00362/14-004 This inspection was a routine, announced inspection of decommissioning activities being conducted at the San Onofre Nuclear Generating Station. In summary, the licensee was conducting site activities in accordance with procedures, license requirements, and regulations.

Organization.

Management, and Cost Controls * The licensee's emergency response and operations organizations were being maintained in accordance with regu l atory and license requ i rements. The inspectors confirmed that the site activ i ties were being conducted consistent with the license and regulatory requirements. (Section 1.2) Self-Assessments.

Audits. and Corrective Act i ons * I ssues were identified by the licensee at appropriate thresholds and generally entered into the correcti ve action process as described in Procedure S0123-XV-50, "Corrective Action Program," Revis i on 31. The inspectors identif i ed examples where the implementation of Procedure S0123-XV-50 was less than adequate, in that, significance level screening of incoming nuclear notifications was not always correct for conditions adverse to qua l ity and significant conditions adverse to quality. The inspectors observed that the implementat i on weakness was due to recent changes to corrective action program procedures that revised the significance level screening process. The inspectors concluded that licensee evaluations determined the significance of i ssues and included appropriate corrective actions. (Section 2.2) Spent Fuel Pool Safety * The licensee was safe l y storing spent fuel i n wet storage. Specifically, the spent fuel poo l was adequately protected from a siphon or drain down event, adequate procedures were ma i nta i ned to restore pool wa t er level and m i t i gate the adverse effects from a dra i n-down event, and spent fue l pool instrumentation, alarms, and leakage detection systems were functioning as required. (Section 3.2) Maintenance and Surve i llance * The licensee continued to maintain plant systems in accordance with Te chnical Specifications requirements, and the licensee continued to review system status and continued to remove systems f rom serv i ce in accordance with procedural instructions. (Section 4.2) * Plant material cond i tion and housekeeping were adequate and had not adversely impacted safe decommissioning or transition. Workers fo ll owed work plans, survei ll ance procedures, industrial safety protocols, and were aware of job controls specified i n work instructions. (Section 4.2) -2-Decommissioning Performance and Status Review * The licensee conducted decommissioning act i vities i n accordance with l icense and regulatory requirements.

Radiation postings and boundaries were maintained in accordance with regulatory requirements.

The licensee continued to make physical changes in the plant to support decommissioning activities. The licensee implemented change notices to update licensing documents as p l ant conditions continued to change during decommissioning.

Fina ll y, the inspectors conducted frequent plant tours to verify that the material condition of structures, systems, and components supported the safe storage of spent fuel and conduct of safe decomm i ssioning. (Section 5.2) Occupational Radiation E xposure * T h e licensee's occupational exposures in 2013 remained below the regu l atory limits. Occupational exposures were attributed to external sources, and no individual was assigned an internal dose during the year. (Section 6.2) Radioactive Waste Treatment and Effluent and Environmental Monitoring

• The licensee implemented its effluent and environmenta l monitoring programs in accordance with license requirements.

No sample exceeded the respective release limit. T h e licensee reported the results in annual reports as required by the license. The licensee's program r esults indicate that no individual membe r of the public received a dose in excess of license or regulatory limits. The licensee continued to i mplement its voluntary groundwater initiative program as required by site procedures, and the licensee reported these samp l e results to the NRC in the annual radioactive effluent re l ease report. (Section 7.2) Solid Radioact i ve Waste Management and Transportation of Radioact i ve Materia l s * The licensee continued to store and ship radioactive wastes in accordance with regulatory requirements. (Section 8.2) -3-Report Details Summary of Plant Status -Units 2 and 3 At the time of this inspection, the two units continued to be permanently shut down. The primary focus at the San Onofre Nuclear Generating Station (SONGS) facility during the inspection period was decommissioning planning.

During the inspection period, the licensee completed and submitted to the NRC the decommissioning cost estimate, irradiated fuel management plan, post-shutdown decommissioning activities report (PSDAR), and the integrated fuel management plan. Additionally, the licensee continued to drain fluids from various plant systems and to abandon systems that were no longer required to be functional.

All systems needed for the safe storage of spent fuel were appropriately maintained. 1 Organization, Management, and Cost Controls (36801) 1.1 Inspection Scope The inspectors reviewed management organization and controls to ensure that the licensee was maintaining effective oversight of decommissioning activities. The inspectors confirmed that commitments associated with the emergency plan and fire protection plan were effectively implemented.

The inspectors also performed an initial review of the PSDAR, licensee schedules, decommissioning plans, and cost management.

1.2 Observations and Findings The inspectors reviewed the licensee's organizational structure to ensure compliance with regulatory and license requirements. In particular, the inspectors compared actual staffing levels with the requirements specified in regulations and the emergency plan, to ensure that the licensee had sufficient staff to conduct plant operations and to respond to emergency situations.

The inspectors also reviewed commitments associated with the fire protection plan and verified compliance with license requirements.

On September 23, 2014, the licensee submitted letters containing the PSDAR, the Site Specific Decommissioning Cost Estimate (DCE), and the integrated fuel management plan for the San Onofre Nuclear Generating Station, Units 2 and 3. The inspectors reviewed the information contained in the PSDAR, attended a sample of daily planning meetings, and reviewed production schedules to determine that activities were consistent with the docketed information.

1.3 Conclusions The licensee's emergency response and operations organizations were being maintained in accordance with regulatory and license requirements. The inspectors confirmed that the site activities were being conducted consistent with the license and regulatory requirements.

Additionally, the inspectors confirmed that no major decommissioning activities had been performed by the licensee. -4 -

2 Self-Assessments, Audits, and Corrective Actions (40801) 2.1 Inspection Scope The inspectors conducted document reviews and interviews with plant personnel to assess the licensee's performance related to the following areas: * Administrative procedures which prescribed actions for the identification, evaluation, and resolution of problems;

• Licensee procedures which prescribed thresholds for the performance of assessments, audits, and surveillances;

• Licensee management review of self-assessments, audits, and corrective actions to remain knowledgeable of plant performance; and * Issues or problems that were identified and corrected in accordance with the licensee's corrective action program (CAP) through a sampling of select issues. 2.2 Observations and Fi ndings The inspectors reviewed CAP documents on a weekly basis to determine: if a sufficiently low threshold for problem identification existed; the quality of follow-up evaluations including extent of condition; and if the licensee assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue. Issues that were repet i tive and those with the potential for safety or regulatory consequence were evaluated further to assess apparent and/or common cause and significance.

During the inspection period, the licensee revised Procedure S0123-XV-50, "Corrective Action Program," to consolidate all of the CAP procedures into one procedure. A key procedure modification was associated with significance level changes to reflect a decommissioned plant status. Specifically, only two of the five significance levels described in Procedure S0123-XV-50 are associated with CAP items, and includes those issues required to be identified and corrected in accordance with 1 0 CFR Part 50, Appendix 8, Criterion XVI. Significance Level 1 was assigned to significant conditions adverse to qua l ity, and Significance Level 2 was assigned to conditions adverse to quality. Significance Levels 3-5 were assigned to business items, or non-CAP items, to be controlled and managed by the responsible manager. The inspectors reviewed all nuclear notifications initiated on a weekly basis, and attended a representative sample of management review committee meetings, to conf i rm that conditions adverse to qua l ity and significant conditions adverse to quality were screened to Significance Levels 1 or 2 to comply with the requirements of 10 C FR Part 50, Appendix 8, Criterion XVI. The inspectors identified serveral examples where conditions adverse to quality that were required to be screened to Significance Leve l 2 in accordance with Procedure S0123-XV-50, Revision 31, were incorrectly screened to lower significance levels to be addressed outside of the regulatory based CAP. The failure to follow Procedure S0123-XV-50 requirements to ensure that the adverse conditions were screened to the correct significance level is being treated as a minor violation because this failure had no safety consequences.

This minor violation is not -5 -

subject to enforcement action in accordance with the NRC Enforcement Policy. The licensee corrected the identified examples to the correct significance levels, and initiated nuclear notifications NNs 203043709 and 203053049 to evaluate and correct the procedure implementation issue. 2.3 Conclusions Issues were identified by the licensee at appropriate thresholds and generally entered into the corrective action process as described in Procedure S0123-XV-50, "Corrective Action Program," Revision 31. The inspectors identified examples where the implementation of Procedure S0123-XV-50 was less than adequate, in that, significance level screening of incoming nuclear notifications was not always correct for conditions adverse to quality and significant conditions adverse to qual i ty. The inspectors observed that the implementation weakness was due to recent changes to CAP program procedures that revised the significance level screening process. The inspectors concluded that licensee evaluations determined the significance of issues and included appropriate corrective actions. 3 Spent Fuel Pool Safety (60801) 3.1 Inspection Scope The inspectors verified the safe wet storage of spent fuel in the Units 2 and 3 spent fuel pools (SFPs). The review included SFP siphon and drain down protection, and SFP instrumentation, alarms, and leakage detection.

3.2 Observations and Findings a. Siphon and Drain Protection The inspectors reviewed the saltwater cooling system, component cooling water system, SFP cooling system, SFP design drawings, and performed a walk down of the SFP, accessib l e SFP cooling system piping, and areas of S FP makeup water piping to evaluate whether conditions existed that represented a siphon or drain path. The inspectors confirmed that licensee procedures properly controlled temporary hoses to prevent an inadvertent drain down of the SFP. The inspectors also reviewed the licensee's abnormal operating procedures relating to a drain down event of the SFP and confirmed that the procedure contained adequate actions to restore S FP water level and mitigate adverse effects from such events. b. Instrumentation.

Alarms, and Leakage Detection The inspectors reviewed the instrumentation and alarms associated with the SFPs to ensure that the strategy was adequate to promptly detect a significant loss of inventory by operations personnel.

Alarm Response Procedure S0(2/3)-15-61.C, "Annunciator Panel 61 C, S FP/RCDT," Revision 9, was reviewed to determine if an appropriate alarm response was prescribed.

A sample of operator rounds and control room logs were also reviewed to verify that operations personnel were monitor i ng the appropriate system parameters and that sufficient details were included to identify problems through data trending. -6 -

The inspectors performed system walkdowns and observed moisture in the leakage detection compartments for both Units 2 and 3. No observable leakage, however, was noted from the tell-ta l e pipe ends to indicate that there was any leakage from the SFP stainless steel liners. Further, leve l trends did not indicate that the SFPs were experiencing abnormal leakage. The condition has been identified and documented in the corrective action program, and the inspectors concluded that the licensee was appropriately evaluating the moisture observed in the leakage detection compartments and that the moisture was not associated with S FP liner degradation or damage. 3.3 Conclusions The licensee was safely storing spent fu e l in wet storage. Specifically, the spent fuel pool was adequately protected from a siphon or drain down event, adequate procedures were maintained to restore pool water level and mitigate the adverse effects from a drain-down event, and SFP instrumentation, alarms, and leakage detection systems were functioning as required.

4 Maintenance and Surveillance (62801) 4.1 Inspection Scope The inspectors reviewed the licensee's maintenance and surveillance activities to verify compliance with Technical Specifications and procedure requirements.

Th e inspectors conducted plant tours throughout the inspection period to observe field conditions, discuss job safety with workers, and to review the impact of work activities on safe decommissioning.

During these walkdowns, the inspectors evaluated material condition and housekeeping, assessed area radiological conditions, radiological access control and associated posting/labeling, and reviewed the overall condition of systems, structures, and components that support decommissioning.

Independent radiation measurements were periodically made by the inspectors in areas toured to determine if those areas were controlled properly and posted as prescribed in 10 CFR Part 20. 4.2 Observations and Findings The inspectors reviewed the licensee's continuing process of system abandonment as it related to maintenance and surveillance activities.

The licensee previously established a program to remove systems and equipment permanently from service in a controlled manner. The licensee previously completed the first review of plant systems and divided the systems into two basic categories-systems to remain functional and systems to abandon. During the inspection period, the licensee continued to remove systems and equipment permanently from service. Fu rther, the licensee continued to identify any constraints for removing systems from service in the future. The licensee plans to analyze the air, fire protection, and electrical

• systems and abandon the systems by area. Similarly, the licensee planned to develop engineering change packages to abandon areas after the systems have been abandoned in the area. The licensee continued to review the preventive maintenance, in-service inspections, and surveillance requirements for systems required to remain functional.

T h e licensee continued to delete unnecessary maintenance activities.

For example, the licensee reduced the number of required preventive maintenance and surveillances for the component cooling water systems from 668 to 23. The licensee was also reconsidering-7 -

the frequencies of the various preventive maintenance activities.

For example, certain component cooling water system preventive maintenance activities were changed from monthly to semi-annually. In summary, the licensee continued to review the functiona l status of remaining plant systems, and the licensee implemented changes in system maintenance based on plant status. The Technical Specifications provide the system requirements for movement of spent fuel. The inspectors confirmed that support systems remained available for future movement of spent fuel. In addition, the licensee continued to maintain generators in functional status for emergency preparedness reasons. The licensee previously removed one diesel-generator per unit from service. 4.3 Conclus i ons The licensee continued to maintain plant systems in accordance with technical specifications requirements, and the licensee continued to review system status and continued to remove systems from service in accordance with procedural instructions.

Plant material condition and housekeeping were adequate and had not adversely impacted safe decommissioning or transition.

Workers followed work plans, surveillance procedures, industrial safety protocols, and were aware of job controls specified in work instructions.

5 Decommissioning Performance and Status Review {71 801) 5.1 Inspection Scope The inspectors evaluated whether the licensee was conducting decommissioning activities in accordance with license and regulatory requirements.

The inspectors conducted document reviews, observations, and interviews with plant personnel to assess the licensee's performance related to the following areas: * Status of decommissioning through the observation of licensee meet i ngs that p l anned, reviewed, assessed, and scheduled the conduct of facility decommissioning;

• Whether licensee activities were in accordance with license conditions and docketed commitments;

• Operability and functionality of systems necessary for safe decommissioning was assessed through control room and plant walk downs including the following systems: radioactive effluent monitoring, spent fuel pool cooling, level and temperature control, radiation protection monitors and alarms, equipment important to emergency preparedness, and equipment that provided normal and standby electrical power; * Operator logs and data taking for normal facility operations, surveillances, maintenance and verification that data out of specification was appropr i ately dispositioned and resolved;

• Assessment of ongoing in-plant work activities to ensure work activities were evaluated for risk in accordance with 10 C FR 50.65(a)(4), operational work risk -8-assessments were performed and operations shift turnovers appropriately communicated pertinent plant status; * Verified appropriate p l ant staffing was maintained and that appropriate management oversight of licensee and supplemental activities were performed;

• Verified pre-job briefings were conducted for facility operations including maintenance, surveillance, operations, and decommission i ng activities

* Verified that system isolations, boundaries and abandonment p l ans for saltwater cooling, emergency core cooling , component cooling water, and electrica l distribution systems ensured proper control of systems important to safe shutdown and did not adversely affect the overa ll plant configuration;

• Performed frequent plant tours to assess field conditions and decommissioning abandonment activities;

• Observed in progress field work to verify activities were conducted in accordance with approved work instructions and workers were knowledgeable of tasks; * Plant materie l condition of structures, systems, and components was maintained at a high level to ensure safe storage of spent fuel; * Verif i ed the storage of combustibles and flammables were in accordance with plant procedures and the f i re plan for the subject location;

• Verified firefighting equipment and stations were properly maintained, i nventoried and readied for use; and * Verif ied that the installed fire detection and suppression systems were effect i vely maintained, surveillances performed, and were capable of performing their intended function. 5.2 Observations and Findings The inspectors reviewed the l icensee's plans for redesign of the electrical power distribution system. As part of this redesign, the regu l ar incoming p l ant electr i ca l distribution lines wou l d be disconnected.

Power for decomm i ssioning would be provided by two main transformers (220 kilovolts to 12 k i lovolts) or two alternate 12-kilovolt connections to offsite power. The licensee plans to install a 12-kilovolt ring bus around portions of the p l ant. Secondary transformers would reduce the 12-kilovolt power to 4, 1 60 or 480 volts for use in the p l ant. Two 4,160 volt portable diesel-generators would be provided for backup power during emergency conditions. The new distr i bution power wou l d then be used to provide power during decommissioning, inc l uding power for spent fuel pool support equipment.

At the end of the inspection, the l i censee continued to design and plan for this change in the plant. The inspectors reviewed the status of the licensee's venti l ation system radiation monitors for compliance with Offsite Dose Calculation Manual (ODCM) requirements. Table 4-3, Radioactive Gaseous Effluent Monitoring Instrumentation, in the ODCM provides the instrument channels required to be operable.

The ventilation rad i ation monitors l i sted in this table include the waste gas holdup system, condenser evacuat i on -9 -

system, plant vent stack, containment purge system, south yard facility work area, and south yard facility decontamination unit. Some of the instrumentation are no longer required to be in service because the licensee had permanently shut down certain ventilation systems. The inspectors questioned the li censee about the status of the two south yard facility radiation monitors.

Both monitors were out of service during the inspection.

The licensee had issued change notices (Nuclear Notifications)

to remove one of two monitors permanently from service and to change the applicability requirements for the second monitor. Section 5.5.2 of the ODCM allows the l icensee to make changes to the ODCM, to retain records of these changes, and to submit an updated copy of the document to the NRC concurrently with the submittal of the annual Radioactive Effluent Release Report. The licensee planned to update the ODCM to ensure that the required status of the various plant ventilation radiation monitors was up to date. The inspectors did not identify any example where a monitor was required to be in service but was not in service. 5.3 Conclusions The licensee conducted decommissioning activities in accordance with license and regulatory requirements. Radiation postings and boundaries were maintained in accordance with regulatory requirements.

The licensee continued to make physical changes in the plant to support decommissioning activities. Th e licensee implemented change notices to update licensing documents as plant conditions continued to change during decommissioning.

Finally, the inspectors conducted frequent plant tours to verify that the material condition of structures, systems, and components supported the safe storage of spent fuel and conduct of safe decommissioning.

6 Occupational Radiation Exposure (83750) 6.1 Inspection Scope The inspectors reviewed occupational radiation exposures to ensure compliance with regulatory requirements. 6.2 Observations and Findings Regulation 10 C FR 20.1201 provides the occupational dose limits for adults. The inspectors reviewed the licensee's occupational exposure records for 2013 to ensure that no individual exceeded regulatory limits. In summary, the licensee's records indicate that no individual exceeded any regulatory limit. Occupational exposures consist of internal and external doses. During 2013, all doses were based on external exposures, and no individual was assigned an internal dose. The licensee's records indicate that approximately 2,000 workers were monitored in 2013, and the collective total effective dose equivalent was 5. 7 rem. The highest dose, 0.299 rem, was assigned to a refueling worker. The next highest assigned dose was 0.178 rem. Both assigned doses are well below the regulatory limit of 5 rem per individual.

-10-The licensee also conducted approximately 1 ,430 whole body counts to monitor for potential uptakes of radioactivity material.

No internal doses were assigned based on these sample results. In addition, no special bioassays were collected by the licensee during the year. The licensee also monitored doses during outage work. The most recent outages for each unit began in 2012 and carried over into 2013. The licensee publicly announced in June 2013 that it would permanently shut down the two units. In October 2013, the licensee elected to change how it categorized site doses. Prior to October 1, 2013, station doses were considered as outage doses, while all doses received after October 1, 2013, were categorized as shutdown doses. Collective outage doses for January 2012 through Septemb e r 2013 totaled 183 person-rem for Unit 2 and 59 person-rem for Unit 3. The shutdown (non-outage) dose for the fourth quarter of 2013 totaled 1.543 person-rem.

The reduction in collective doses was reflective of the reduction of work in the plant. The inspectors also reviewed the licensee's as low as reasonably achievable (ALARA) goals for 2014 for site staff. As of July 2014, the licensee estimated that collective doses in 2014 would total about 973 millirem. The major work projects included routine and non-routine radiation protection and chemistry, operations, and maintenance work. No special, high-dose project work was scheduled for 2014. 6.3 Conclusions The licensee's occupational exposures in 2013 remained below the regulatory limits. Occupational exposures were attributed to external sources, and no individual was assigned an internal dose during the year. 7 Radioactive Waste T reatment and Effluent and Environmental Monitoring

{84750) 7. 1 Inspection Scope The inspectors reviewed the licensee's effluent and environmental monitoring programs to ensure that the licensee effectively controlled, monitored, and quantified releases of radioactive materials in liquid, gaseous, and particulate forms to the environment.

7.2 Observations and Findings Technical Specifications, Sections 5.5.2, for the two licenses required the licensee to establish, implement, and maintain the ODCM. The ODCM provides detailed guidance for monitoring and controlling liquid and gaseous effluents as well as calculating offsite doses. The ODCM also provides the requirements for the radiological environmental monitoring program. In addition, Technical Specifications, Sections 5. 7.1, required the licensee to submit annual radiological environmental and radioactive effluent release reports to the NRC. The inspectors reviewed the licensee's implementation of the ODCM and reviewed the two most recent annual reports. a. Effluent Monitoring The licensee submitted the annual radiological effluent release report for 2013 to the NRC by letter dated April 22, 2014. This report summarizes all gaseous and liquid -1 1 -

effluents for 2013 as well as radioactive waste shipments.

The inspectors reviewed the annual report and se l ected data used in the development of the report, compared the information provided in the report against the requ i rements provided in the ODCM, and interviewed licensee staff about the development of the annual report. In summary, the inspectors confirmed that the ODCM release limits were not exceeded in 2013. The inspectors compared the gaseous effluent releases to the limits provided in the ODCM. The licensee measured releases from fission and activation gases, iodines, particulates, and tritium. All releases in 2013 were less than 1-percent of the applicable effluent concentration limit. The licensee also calculated the potential radiation doses at the site boundary based on these gaseous effluents. The radiation doses were less than 1-percent of the app l icable limits specified in the ODCM. The inspectors also compared the liquid effluent releases to the ODCM limits. The licensee monitored releases of fission and activation products, tritium, dissolved and entrained gases, and gross alpha radioactivity.

All releases in 2013 were less than 1-percent of the applicable eff l uent concentration limit. Similar to gaseous effluents, the licensee calculated rad i ation doses from liquid effluents at the site boundary. All doses were less than 1-percent of the applicable limits specified in the ODCM. Total body doses were calculated to be less than 1 millirem.

The annual radioactive effluent release report summarized the radioactive waste shipments for 2013. The licensee shipped spent resins, filters, filter sludge, and dry active wastes during the year in 32 individual shipments.

b. Environmental Monitoring The inspectors reviewed the annual radiological environmental operating report for 2013, submitted by the licensee to the NRC by letter dated May 7, 2014. The purposes of the licensee's radiological environmental monitoring program are to quantify ambient radiation levels and concentrations of radioactivity in the vicinity of the site. The licensee's environmental monitoring program consisted of measurement of ambient gamma radiation levels, collection of airborne radioiodine and particulates, and collection of various soil, water, sediment, plant, and marine samples. The inspectors compared the licensee's environmental monitoring program implementation to the requirements provided in the ODCM. The inspectors confirmed that the licensee collected the samples required by the ODCM. The l icensee's sample results confirmed that the public dose limit was not exceeded. The ODCM requires the licensee to measure ambient gamma radiation at 30 locations. The licensee measured ambient gamma radiation levels at 49 locations including 12 onsite and two contro l locations.

The highest gamma radiation measurement was recorded inside the plant at the south yard facility, the location where radioactive materials were being stored. This location measured 98 millirem for the year, with an average control (background)

of about 67 millirem.

The public exposure was estimated to be less than 1 millirem.

The licensee sampled for airborne radioiodine and particulates at eight locations including one onsite and one control location.

Th e ODCM requires 5 sampling locations.

No sample result exceeded the reporting levels provided in the ODCM. The licensee -12-also collected soil, ocean water, drinking water, sediment, non-migratory marine animal, local crops, and kelp samples. The licensee collected more than the minimum number of samples required by the ODCM. In summary , the sampling identified low levels of cesium-137 in soil and animals that were attributed to atmospheric fallout. Low levels of lodine-133 were also identified in kelp samples. The iodine-133 was attributed to medical wastes in ocean water. Based on the samples collected in 2013, the licensee concluded that the site had negligible radiological impact on the environment.

Based on the licensee's sample results, the inspectors concluded that the dose l i mit for individual members of the public (1 00 millirem per year) provided in regulation 10 CFR 20.1301 (a) was not exceeded in 2013. Section 5.2 of the ODCM provides the requirement for the land use census. The annual radiological environmental operating report for 2013 included an updated land use census. The land use census provided a description of the nearest milking animal , residence, and garden. c. Groundwater Protection Initiative The licensee collected groundwater samples around the site as part of its voluntary implementation of the i ndustry groundwater protection initiative.

The sampling program is described in site procedures.

The sample results are presented in an attachment to the annual radioactive effluent release report. The licensee sampled nine wells as part of the initiative. The licensee also sampled several other investigat i on wells at a variable frequency.

The licensee collected 263 groundwater samples in 2013. The li censee's sample results indicate that measurable concentrations of tritium (hydrogen-3) was occasionally identified in samp l es collected from wells located with i n the former Unit 1 footprint.

The inspectors noted that none of the sample results exceeded the drinking water quality standard established by the U.S. E nvironmental Protection Agency; although, the shallow groundwater at the site is not a source of drinking water. The l icensee continues to implement a shallow groundwater extraction plan by pumping shallow groundwater at the former Unit 1 site. The water is discharged to the environment through a monitored discharge pathway. 7.3 Conclusions The licensee implemented its effluent and environmental monitoring programs in accordance with license requirements.

No sample exceeded the respective release limit. The licensee reported the results in annual reports as required by the license. The licensee's program results indicate that no individua l member of the public received a dose in excess of license or regulatory limits. The licensee cont i nued to implement its vo l untary groundwater initiative program as requ i red by site procedures, and the l icensee reported these sample results to the NRC in the annual radioactive effluent release report. -13 -

8 Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750) 8.1 Inspection Scope The inspectors reviewed the licensee's radioactive waste management and transportation activities to determine whether the licensee properly processed, packaged, stored, and shipped radioactive materials. T he inspectors observed numerous activities associated with spent resin removal from the plant. 8.2 Observations and Findings The inspectors reviewed the status of the licensee's radioactive wastes in storage and shipments made in 2014. The licensee continued to store spent resins in the plant. The resins were removed from systems, including the spent fuel cooling and cleanup system, and stored in two spent resin tanks. During the inspection period, the licensee transferred a majority of the spent resins out of the tanks and into liners. The licensee dried and stored the resins in the liners to prepare for disposal in accordance with regulatory requirements.

The licensee continues to store legacy wastes from plant operations.

The licensee was conducting an inventory of the wastes to verify what wastes remained in storage. T he wastes may be reclassified based on the age and decay time of the wastes in storage. The licensee had approximately 80 containers in storage. These containers were used for storing equipment such as scaffolding. The licensee plans to sort the material for asset recovery, disposal, or future use during decommissioning. The licensee also had several drums of water/oil mixture in storage. T h e licensee planned to decant the water, dry the residual material, and ship the residual material to a processor for incineration.

The licensee continued to store material in the North Industrial Area, located within the former Unit 1 footprint.

The licensee stored the Unit 2 reactor head ventilation and upper shroud in this area. The licensee planned to ship the material for disposal in the near future. T he inspectors compared the material in storage around the plant to regulatory requirements.

The inspectors noted that the licensee continued to maintain adequate control over radioactive material in storage, post the areas where the radioactive material was being stored, and maintain proper radioactive material labeling for each container.

The inspectors reviewed the status of radioactive wastes shipments in 2014. At the time of the onsite inspection, the licensee had completed 13 shipments.

The material shipped included mixed dry active wastes, missile shield from Unit 2, and spent filters. The material was shipped directly to the disposal site or a third-party for processing and volume reduction prior to disposal.

Finally, the inspectors reviewed one representative shipping paper. The shipment consisted of cartridge filters in a Type A cask being used as a general design package (IP-1 package).

The licensee shipped the material as a Low Specific Activity LSA-11 shipment.

The inspectors confirmed that the licensee had correctly classified the material, and the radiological criteria for this type of shipment met regulatory-14-requirements. In summary, the licensee's records indicate that the shipment complied with regulatory requirements prior to shipment.

8.3 Conclusions The licensee continued to store and ship radioactive wastes in accordance with regulatory requirements. 9 Other Activities 9.1 (Closed) V I O 05000362-2012-009-02

Failure to Verify Adequacy of Thermal-Hydrau l ic and Flow-Induced Vibration Design for the Unit 3 Replacement Steam Generators. In a Notice of Violation dated December 23, 2013, the NRC provided the final results of a preliminary White finding identified in NRC I nspection Report 05000361/2012009; 05000362/2012009, dated September 20, 2013, involving the failure to verify the adequacy of the therma l-hydraulic and flow-induced vibration design of the Unit 3 replacement steam generators, which resulted in significant and unexpected steam generator tube wear and the loss of tube integrity on Unit 3 Steam Generator 3E0-88 after 11 months of operation (ML13357A058). The cover letter of the Notice of Violation specifically stated "If you determine that any reason for this violation may apply to work activities during decommissioning and dry cask storage, including oversight of contractor activities, then for each such reason, your reply should include: (1) the corrective steps that have been taken and the results achieved, (2) the corrective steps that will be taken, and (3) the date when all associated corrective actions will have been implemented." On January 22, 2014, the licensee submitted a reply to the Notice of Violation and informed the NRC that they had concluded that the reasons for the violation would not reasonably apply to decommissioning and spent fuel storage activities including dry cask storage (ML14024A390).

On May 21, 2014, the licensee completed an Organ iza tional and Programmatic root cause analysis, which was performed to evaluate the SC E organizational and programmatic causes of the event related to the replacement steam generator tube-tube wear and retainer bar wear. Consistent with earlier cause evaluations, the licensee concluded that the reasons for the vio l ation wou l d not reasonably apply to decommissioning and spent fuel storage activities including dry cask storage. The inspectors reviewed the root cause analysis and confirmed that there were no additional issues identified that could impact the licensee's ability to safely decommission the San Onofre Nuclear Generating Station. The NRC has concluded that inspections associated with previous Augmented Inspection Team inspections (ML12188A748 and ML12318A342), Confirmatory Act i on Letter Response inspection (ML13263A271

), and the inspectors'

review of the Organizational and Programmatic Root Cause Analysis has met the objectives of Inspection Procedure 95001, "Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area," to provide assurance that: (1) the root causes and contributing causes of risk-significant performance issues were understood; (2) the extent of condition and extent of cause of issues were identified; and (3) corrective-15 -

actions were sufficient to address the root and contributing causes and prevent recurrence.

Therefore, the violation is closed. 10 Meetings, Including Exit On July 17, 2014, inspectors from the Repository and Spent Fuel Safety Branch, Region IV, presented the results of onsite inspection activities performed during the week of July 14 to Mr. B. Sheller, Shutdown Plant Manager, and other members of the licensee's staff. On October 8, 2014, the inspectors presented the final inspection results to Mr. Thomas J. Palmisano, Vice President and Chief Nuclear Officer, and other members of the licensee's staff. T he inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

No proprietary information was identified. -16-SUPPLEMENTAL INSPECTION INFORMATION K E Y POINTS OF CO NTA CT Licensee Personnel E. Avella, Director, Decommissioning Initial Activities L. Bosch, Manager, Oversight and Nuclear Safety Concerns J. Davis, Manager, Operations D. Evans, Senior Nuclear Engineer, Regulatory Affairs and Emergency Preparedness K. Flynn, Manager, Decommissioning Planning T. Gallaher, Manager, Corrective Action Program/Performance Improvement J. Madigan, Director, Technical Advisor to CNO M. Moran, Manager, Engineering M. Morgan, Senior Nuclear Engineer, Regulatory Affairs and Emergency Preparedness R. Quam, Manager, Security B. Sheller, Shutdown Plant Manager A. Sterdis, Manager, Regulatory Affairs and Emergency Preparedness IP 36801 IP 40801 IP 60801 I P 62801 IP 71801 IP 83750 IP 84750 IP 86750 Opened None Closed INSPECTION PROC ED URES USED Organization, Management, and Cost Controls Self-Assessments, Audits, and Corrective Actions Spent Fuel Pool Safety Maintenance and Surveillance Decommissioning Performance and Status Review Occupational Radiation Exposure Radioactive Waste Treatment and Effluent and Environmental Monitoring Solid Radioactive Waste Management and Transportation of R adioactive Materials I TEMS OPENED, CLOSED, AND DISCUSSED 05000362/2012-009-02 VI 0 Failure to Verify Adequacy of Th ermal-Hydraulic and Induced Vibration Design for the Unit 3 Replacement Steam Generators Discussed None Attachment ADAMS A LARA CAP CFR DCE IP NRC ODCM PSDAR SFP SONGS LIS T OF ACRONYMS Agencywide Documents Access and Management System As Low As Reasonab l y Achievable Corrective Action Program Code of Federal Regu l ations Decommissioning Cost Estimate Inspection Procedure U.S. Nuclear Regulatory Commission Offsite Dose Calculation Manual Post-Shutdown Decommissioning Activities Report Spent Fuel Pool San Onofre Nuclear Generating Station LIST OF DOCUMENTS REVIEWED Section 2: Self-Assessments, Audits, and Corrective Actions PROCEDURES NUMBER S0123-XV-50 Corrective Action Program NUCLEA R NOTIFICA TI ONS NUMBE R 2027829 202782073 58 2029204 20 2776 625 07 Section 3: Spent Fuel Pool Safety PROCEDURES NUMBER 202844394 Loss of Spent Fuel Pool Cooling Shutdown Cool in g System Operation 202791908 S023-13-23 S023-3-2.6 S023-2-8.1 Saltwater Cooling System Removal/Return to Service Evolutions S023-3-2.11 S023-3-2.11.1 Spent Fuel Pool Operations SFP Level Change and Purification Crosstie Operations -2 -REVISION 30 202915280 REV I SION 12 36 25 37 EC 1 22 NUCL E AR NOTIFICA TI ONS NUMBER 202718455 202371901 TITLE DRAWINGS NUMB ER 40122 P & I Diagram-Fuel Pool Cooling System Section 4: Maintenance and Surveillance NUCLEAR NOTIFICATIONS NUMBER 2026996 202694463 96 2026727 202672720 21 MISCELLANEOUS 202622291 202694158 202532665 Engineering Decommissioning Paper-Deactivation of Radiation Monitoring System Preventative Maintenance Plans on Reliability Maintenance Rule Function Report-Rad-Mon SONGS System Health Report -First Quarter 2013 Maintenance Rule Expert Panel Meeting Package, Dated December 18, 2013 Section 5: Decommissioning Performance and Status Review PROCEDURES NUMBER S023-3-2.11 S023-XX-10 TITLE Spent Fuel Pool Operations Maintenance Rule Risk Management Program Implementat i on NUCLEAR NOTIFIC ATI ONS NUMBER 202719402 -3 -REVISION 39 9